Aeromodelling

Regulatory framework for model aircraft

Aeromodels and model aircraft are subject to compliance with Implementing Regulation (EU) 2019/947, provided that such flights are not carried out inside buildings or completely enclosed spaces.

In Spain, Royal Decree 517/2024, of 4 June, develops the legal regime for the civil use of unmanned aircraft systems (UAS). Aeromodelling activities, in addition to being subject to the applicable provisions of the Basic Regulation, the Delegated Regulation and the Implementing Regulation, will be subject to the provisions of this Royal Decree.

Registration as UAS Operators

Regardless of the different options indicated later for the practice of model aircraft, all pilots of model aircraft must be registered as UAS operators whenever they intend to perform flights:

With model aircraft having a maximum take-off mass (MTOM) greater than 250 grams or capable, in the event of a collision, of transferring to a human a kinetic energy greater than 80 joules (e.g.racerdrones).
With aeromodels that have sensors capable of capturing personal data and are not considered toys (according to Directive 2009/48/EC), such as with a photo or video camera from MTOM< 250g, except toys.
In ‘specific’ category (Art. 14(5)(b) Reg. (EU)2019/947).

Registration as a UAS operator is free of charge and is done through AESA's website. To make such a registration there are two options:

At the individual level (required Electronic DNI, digital certificate or scanned DNI), according to the instructions provided in the UAS/drones operator registration section of the AESA website.
Within the framework of a model aircraft club or association, giving permission to the club or association to register them on its behalf. For this purpose, the following registration guide for model aircraft clubs and associations is available:

UAS Operator Registration Guide for Ed.03 Model Aircraft Clubs and Associations

The minimum age to register as a UAS operator is 16 years. For those users with a lower age, they must operate under the cover of a registered UAS operator.

With regard to aircraft registration in the EASA application, there is only an obligation to register model aircraft when it is intended to operate in a “specific” category.

With regard to the registration of unmanned aircraft with the Ministry of the Interior, UAS weighing 250 g or more, or equipped with a sensor capable of capturing personal data whatever their maximum mass, must be registered, unless it is in accordance with Royal Decree 1205/2011 of 26 August 2011 on the safety of toys.

Insurance

Liability insurance covers the liability of the operator in case of damage to the property of third parties or injury to persons as a result of the operation.

This insurance will be mandatory for UAS operators:

with a maximum mass of 20 kg or more and a maximum mass of less than 20 kg:
- in the ‘open’ category, within subcategory A2;
- in the “specific” category, in any form; o
- in the category “certified”.

When UAS operations are carried out within the framework of model aircraft clubs or associations authorized by AESA, the insurance obligation may also be fulfilled when the club or association has an insurance policy that covers the civil liabilities of all UAS operations of its members.

Flight with aeromodels

Currently, the practice of model aircraft in Spain can be carried out following any of the following options, as long as the conditions defined in each of them are met and you are registered as a UAS operator as indicated in the previous section:

OPTION 1 Flights in "open" category meeting the particular requirements of subcategory A3 according to Regulation (EU) 2019/947

These flights must be carried out in areas where no non-participating person is endangered and at a horizontal distance of at least 150 m from residential, commercial, industrial or recreational areas. In addition, the maximum ground flight height limitation of not more than 400 ft (120 m) shall be respected.

Model aircraft shall have a maximum take-off mass of less than 25 kg and pilots shall have passed the training and examination for subcategory A1/A3.

For more information on the operation requirements in subcategory A3 click here.

More information on remote pilot training and examination in subcategory A1/A3 here.

The minimum age of 16 years for remote pilots in the "open" category may be reduced in the following cases:

12 years for the use of UAS C0 or Legacy of less than 250 g in subcategory A1;
At 14 years of age:
- for the use of Class C1 UAS in subcategory A1;
- for the use of Class C2 UAS in subcategory A2 and A3;
- In subcategory A3 when operating:
  - UAS of Classes C3 and C4;
  - UAS of private construction of less than 25 Kg.
  - UAS Legacy of more than 250 g, up to 25 Kg.

OPTION 2 Flights in particular geographical areas

A UAS geographical area is defined as a part of the airspace established by the competent authority that facilitates, restricts or excludes UAS operations in order to manage risks to safety, security, privacy, protection of personal data or the environment.

Pursuant to Article 15 of Implementing Regulation (EU) 2019/947 and Article 36 of Royal Decree 517/2024, the Interministerial Committee provided for in Article 6 of Law 21/2003, the body responsible for airspace structuring, may designate particular geographical areas in which UAS operations are exempt from one or more requirements of the ‘open’ category.

The Interministerial Commission has defined particular UAS geographical areas to carry out model aircraft activities in subcategory A3, with exemptions for the ‘open’ category, in accordance with Article 46 of RD 517/2024, which waives compliance with minimum age requirements and remote pilot training established in Implementing Regulation (EU) 2019/947, in all fields of model aircraft published in the AIP, provided that the following alternative measures are complied with:

Development of specific training material including the non-conflict scheme;
Explanation of the rules of procedure;
Instruction by experienced pilots;
Gradual initiation of the flight of novice pilots and pilots under 16 years of age;
Ongoing supervision and advice by experienced pilots;
Ensure a kinetic energy of less than 34 KJ in operations and, a margin for risk on land of at least 120 m.

OPTION 3 Authorisation issued by the competent authority for operations with UAS under cover of a model aircraft club or association

Depending on the operations to be carried out, if they cannot be framed within the open category (option 1) or no geographical area has been established (option 2), the issuance of an operational authorization issued by EASA at the request of a model aircraft club or association will be necessary.

In accordance with Article 16 of Implementing Regulation (EU) 2019/947 and Section 2 of Chapter II of Royal Decree 517/2024, a model aircraft club, association or federation may request AESA to issue an authorisation to carry out operations with UAS in the framework of model aircraft clubs or associations.

To obtain an operational authorization the club or association must be legally constituted as such, being its responsibility:

Control that its members carry out the flights in accordance with the conditions and limitations of the authorization
Have insured the risks of all UAS operations of its members within the scope of authorization
Take appropriate action when it is found that the operational limitations of the authorization have been exceeded.
Event reporting

As an example, operations that would require operational authorization would be as follows:

Performed at a height exceeding 120 m;
Performed with aircraft with an MTOM exceeding 25 kg;
Carried out with non-privately manufactured aircraft with a combustion system;
Involving the overflight of concentrations of persons;
Performed beyond the pilot's visual range (BVLOS);

Authorisations which AESA may issue to model aircraft clubs or associations shall be made in accordance with the procedures, organisational structure and management system of the model aircraft club or association, ensuring that:

Pilots flying within the framework of the model aircraft club or association are aware of the limitations and conditions defined in the authorisation;
Pilots flying in the framework of the model aircraft club or association are assisted to reach the minimum competition that allows them to pilot the UAS safely;
The model aircraft club or association takes appropriate action when it is aware that a pilot does not comply with the conditions and limitations defined in the authorisation;
The model aircraft club or association provides AESA with the necessary documentation for monitoring and follow-up purposes.

The authorisation issued by EASA shall specify the conditions under which flight operations with model aircraft may be carried out within the scope of the club or association. Such authorisation shall be limited to the national territory.

To request an authorisation for UAS operations in the framework of model aircraft clubs and associations, the interested party may address his request to the AESA UAS Division through the procedure authorized for that purpose. A guide for submitting applications for authorisation is available to clubs or associations at the following link:

Operating Authorisation Submission Guide for Model Aircraft Ed.04

In any case, the request must be made by the representative of the model aircraft club, association or federation, attaching the operations manual that satisfies the requirements set out in paragraph 2(b) of Article 16 of Implementing Regulation (EU) 2019/947. For the preparation of the required operations manual, it has the following guidance material with the minimum content to include:

Guidance material on the manual of a federation, association or model aircraft club Ed.02